لایب سان

Author(s): OECD.

Year: 2021

ISBN: 9789264699755

 5 TYPOLOGY OF CORRUPTION RISKS IN COMMODITY TRADING TRANSACTIONS © OECD 2021 Table of contents Foreword 3 Acknowledgements 4 Executive summary 7 1 Corruption risks across commodity trading transactions: An overview 8 Opacity of ownership and governance structures of key actors involved in commodity trading 9 Use of corporate vehicles in commodity trading transactions 10 Use of front companies to purchase commodities 11 Use of joint venture structures in commodity trading transactions 11 Concealment of beneficial owners of buyers 13 Involvement of politically exposed persons in commodity trading transactions 15 Use of intermediaries in commodity trading transactions 16 Lack of or insufficient corporate due diligence 17 Note 18 2 Corruption risks in the buyer selection process 19 Opacity of the selection of buyers 19 Use of bribery to secure commodities 21 Existence of conflicts of interest between buyer and seller 21 3 Corruption risks in the terms of the sales agreement 23 Lack of transparency of the key terms of the transaction 23 Additional risks associated with the use of non-conventional sales agreements 24 Resource-backed finance agreements 24 Commodity-for-product-swap-agreements 25 4 Corruption risks in the transfer of the commodities 27 Misinvoicing of commodities 27 Misreporting of grade and valuation 28 Misreporting of volume 28 6  TYPOLOGY OF CORRUPTION RISKS IN COMMODITY TRADING TRANSACTIONS © OECD 2021 5 Corruption risks in the collection of the payment 30 Opacity of the revenue flows 30 Manipulation of the foreign exchange rate 31 Lack of transparency of the payment account 31 References 33 Annex A. OECD initiatives on corruption in commodity trading 37 Thematic Dialogue on Commodity Trading Transparency 37 Illicit Financial Flows in Oil and Gas Commodity Trading 37 Tables Table 4.1. Risk of undervaluation for minerals and metals 28 Figures Figure 1.1. Commodity trading transactions: 4 segments where corruption risks may arise 8 Figure 1.2. Percentage of subsidiaries controlled by holding companies registered in offshore financial centres 14 Figure 2.1. Red flags of corruption risks that can arise during the buyer selection process 19 Figure 3.1. Red flags of corruption risks that can arise in the negotiation of terms of a sales agreement 23 Figure 4.1. Red flags of corruption risks that can arise in the transfer of the commodities 27 Figure 5.1. Red flags of corruption risks that can arise in the collection of the payment 30 Boxes Box 1.1. Red flags of corruption risks of cross-cutting relevance across commodity trading transactions 9 Box 1.2. OECD definition of a joint venture 12 Box 1.3. Financial Action Task Force: Definition of beneficial ownership 13 Box 1.4. Financial Action Task Force: Definition of politically exposed persons 15 Box 1.5. OECD definition of intermediaries 16 Box 2.1. OECD definition of conflict of interest 22

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